Data Management & Business Records Policy
1. Purpose and Scope
This Policy establishes how KWR creates, maintains, protects, organizes, retains, and manages Business Records and engineering documentation. Good engineering depends on good documentation.
2. Guiding Principles
- Accuracy over assumptions;
- Documentation supports engineering;
- Records should be clear and traceable;
- Important project history should be preserved;
- Customer information must be protected;
- One authoritative record should be used whenever reasonably practicable.
3. Business Records
Business Records include documentation reasonably necessary to conduct, support, document, or verify Products, Services, engineering activities, Customer relationships, financial transactions, operational activities, and legal compliance.
- Estimates, repair orders, invoices, and work records;
- Vehicle and project intake records;
- Engineering notes, Progress Records, diagnostics, calibration files, ECU backups, data logs, photographs, wiring and CAN documentation;
- Customer communications, warranty records, shipping and payment records;
- Quality Control documentation and completion records.
4. Engineering Records
Engineering Records may include Engineering Baselines, Original Vehicle Configuration, Original System Configuration, diagnostic observations, calibration history, revision history, configuration changes, programming records, validation results, and engineering recommendations.
5. Progress Records
Progress Records document significant project milestones such as status updates, photographs, engineering observations, Customer approvals, configuration changes, Quality Control activities, testing, and completion notes.
6. Evidence Integrity
Customer-provided information, KWR observations, and KWR engineering conclusions are distinct categories and should remain distinguishable in the record. KWR makes reasonable efforts to maintain accurate records based on information available when the record is created; records do not guarantee future conditions or information that was unavailable at the time.
7. Retention and Archiving
KWR retains Business Records for periods reasonably necessary to support customer service, engineering reference, warranty administration, legal compliance, accounting, operational continuity, and legitimate business interests. Different records may have different retention periods. Inactive records may be archived while preserving appropriate future access.
8. Confidentiality and Access
Business Records may contain confidential Customer information, calibration files, proprietary engineering material, security information, and other protected information. Access is limited to personnel and qualified service providers with a legitimate business need.
9. Configuration and Revision History
Significant changes to Vehicle Configuration, Original System Configuration, engineering recommendations, calibration files, project scope, Customer approvals, or other material project information should be documented. Subsequent changes should preserve history rather than overwrite or obscure earlier records.
10. Customer Access and Internal Records
Customers may request copies of records relating to their own projects subject to applicable law, confidentiality, intellectual-property rights, manufacturer restrictions, and legitimate business considerations. Internal engineering notes, proprietary calibration methodologies, internal Quality Control documentation, security procedures, trade secrets, and similar internal records are not automatically Customer deliverables merely because they relate to a Customer project.
11. System of Record
Where an approved KWR business system is designated as the System of Record for an operational process, separate duplicate records should not be created unless duplication serves a legitimate engineering, financial, legal, operational, continuity, or customer-service purpose. KWR's existing shop-management software is the System of Record for the transactional functions it already manages.
12. Continuous Improvement and Administration
KWR reviews documentation practices, engineering procedures, record-management processes, and operational workflows to improve accuracy, efficiency, Quality Control, customer service, and long-term knowledge preservation.